Wm. Snyder being duly sworn deposes and says:

I have been engaged most of the time in the oil business in the drilling, operation and pumping of oil wells since 1861, and tanking and taking care of oil since 1861. My experience embraces operating in Pennsylvania and California. I left Pennsylvania and came to California in October 1876 and commenced working in the refinery of the defendant corporation at Ventura, then went to the refinery at Lyon’s Station, worked there until March 1877, when I went up and assisted in drilling and deepening some of the Pico wells.

I stayed there for a time and have since been engaged in the oil business. I consider myself as an expert in the drilling and operating of oil wells and also as a still man in oil refineries.

I have never seen any of the Pico wells plugged so as to obstruct the flow of oil and do not believe such a thing was ever done. An oil saver was used, but as this is such a common device among oil men and is so universally used in oil wells whose flows are expected, I would not have thought anyone would have claimed that such a saver obstructed the flow of oil or gas, or plugged the well, and am astonished that any one should think the well was plugged. The so called plugging mentioned by Loomis in his affidavit was evidently an oil saver, as I remember we did on same instance strap it to the casing, where the casing had been out and there was no head on it. I know that in Pennsylvania, the larger number of wells are pumped by head and the theory that the wells must be pumped continuously or on a vacuum, has long since been exploded and proved false.

I know C.A. Mentry and believe him to be a careful, skillful, and conscientious driller and operator of oil wells and think that said wells have been operated in a proper and workmanlike manner. I believe that in California, oil deteriorates much more rapidly than in Pennsylvania and I have been informed that after being tanked a short time they become too heavy to profitably refine them for illuminating oils. I am not interested in said suit and not in the employment of any parties thereto.

Wm Snyder

July 15, 1878